Baking polymer clay is an exact science.

You need to know the right way to bake your creations if you want them to last a lifetime. Why does polymer clay need to be baked? Polymer clay is made of Polymer Polyvinyl Chloride (PVC) and liquid plasticizers . These plasticizers are what make the clay pliable. To harden the clay, the pla sticizers need to be burned off, thus the need for baking. What happens if you do not bake the clay properly? The number one mistake most newbies make is under-baking the clay. When polymer clay is exposed to heat, even if not at the right settings, it still hardens. Ho wever, not all the plasticizers are completely burned off, leaving some parts of the piece raw. This mistake is not immediately noticeable. After a few months o r even years, however, the chemicals left in the half-baked piece will begin to "eat" the clay. This makes the piece crumbly. How do I make sure I do not under-bake the clay? Make sure you bake at the right temperature, for the right duration. Always foll ow the baking instructions indicated in the polymer clay package. Remember, the baking time indicated is always the minimum. What equipment is used to bake polymer clay? Polymer clay needs to be cured at an exact temperature for an exact period of ti me. That said, you can use whatever equipment that produces heat, as long as it consistently gives out heat at the exact baking temperature for the right durati on. Below is a rundown of polymer clay brands I use (and trust) and their baking temperatures (in degrees celsius) and times. Different brands have different se ttings, so always check the package instructions. * Premo - 130C, 30 minutes minimum * Cernit - 101C to 132C, 5 to 20 minutes, depending on size * Fimo Classic - 129C, 30 minutes minimum Your best bet is to use a regular oven used to bake food. It has a temperature c ontrol knob and a timer - all you'll ever need. The oven I use I've owned for ye ars. I bought it for P1,600, but now it retails for P1,700 to P1,800. There are cheaper models you can buy, but I chose one with the convection fan. Can I bake polymer clay in a bread toaster? If your bread toaster has a temperature control knob which allows you to set the temperature at exactly 130 degrees celsius (or whatever setting your clay requi res), it's fine. But if your toaster only has a simple low-medium-high heat knob , it's hard to keep the temperature at the right setting for the right duration. Unless you tweak your baking method using only your bread toaster, chances are your piece will turn out half-baked (hard outside, but still crumbly inside) or burnt. Why not save time, effort, and clay by using the right equipment early on , right? Why is proper baking so important? Polymer clay is plastic, so it's supposed to last forever. But when you do not f ollow proper baking procedures, you'll end up with a disposable piece. When a po lymer clay piece is half-baked, the clay inside still has some plasticizers that can leach or eat your piece, making it crumbly a few months or years after. On the other hand, when you over-bake the piece, the plastic will burn, giving off toxic fumes that will harm you and the environment. This is Part 3 of a series, a Handmade Pilipinas post Read Part 1 here. Read Part 2 here.

com. join our workshops! Email me at angelisartbeads@gmail. executive or judicial branches of government by no means prescribes for absolute autonomy in the discharge by each of that part of the governmental power assigned to it by the sovereign people. ______________________________ Francisco Vs. Once an impeachment complaint has been initiat ed. Beyond this. No. it did not go about assuming j urisdiction where it had none. this Court i s ever mindful of the essential truth that the inviolate doctrine of separation of powers among the legislative. Jr. House Of Representatives [G. Thus when a proposal reached the floor proposing that "A vote of at least one-third of al l the Members of the House shall be necessary to initiate impeachment proceedings . section 3 of Article XI of the Constitutio n. Hel d: In passing over the complex issues arising from the controversy. the Rules of Procedure in Impeachment Proceedings which were approv ed by the House of Representatives on November 28. . Da vide. with the House of Representativ es falls within the one year bar provided in the Constitution and whether the re solution thereof is a political question has resulted in a political crisis. Co nsequently. The Court in the present petitions subjected to judicial scrutiny and resolved on the merits only the main issue of whether the impeachme nt proceedings initiated against the Chief Justice transgressed the constitution ally imposed one-year time bar rule. nor indiscriminately turn justiciable issues out of decidedly political questions because it is not at all the business of this C ourt to assert judicial dominance over the other two great branches of the gover nment. the meaning of Section 3 (5) of Article XI becomes clear." This is a misreading of said provision and is contrary to the principle of re ddendo singula singulis by equating "impeachment cases" with "impeachment procee ding. To the argument that only the House of Representatives as a body c an initiate impeachment proceedings because Section 3 (1) says "The House of Rep resentatives shall have the exclusive power to initiate all cases of impeachment ." this was met by a proposal to delete the line on the ground that the vote of the House does not initiate impeachment proceeding but rather the filing of a co mplaint does. The controversy in front of the Court was the constitutionality of the subse quent filing of a second complaint to controvert the rules of impeachment provid ed for by law.R." Having concluded that the initiation takes place by the act of filing and referral or endorsement of the impeachment complaint to the House Committee on Justice or. Issue: Whether or not the filing of the second impeachment compla int against Chief Justice Hilario G. by the filing by at least one-third of the members of the House of R epresentatives with the Secretary General of the House. 10 Nov 2003] Facts: Imp eachment proceedings were filed against Supreme Court Chief Justice Hilario Davi de. Davide. Thus. Jr is barred under paragraph 5.For more information. 160261. 2001 are unconstitutional. another impeachment complaint may not be filed against the same official wit hin a one year period. The framers o f the Constitution also understood initiation in its ordinary meaning. the second impeachment complaint against Chief Justice Hilario G.

300. But a provisio n which is complete in itself and becomes operative without the aid of supplemen tary or enabling legislation. the legislature may st ill enact legislation to facilitate the exercise of powers directly granted by t he constitution. provide a convenient remedy for the protection of the rights secured or the determination thereof. perhaps apprehensive that GSIS has disregarded the tender of the matching bid and that the sale of 51% of the MHC may be hastened by GSIS and consummated with Renong Berhad. The mere fact that legislation may suppleme nt and add to or prescribe a penalty for the violation of a self-executing const itutional provision does not render such a provision ineffective in the absence of such legislation. pursuant to the privatization program of the Phi lippine Government under Proclamation 50 dated 8 December 1986. furth er the exercise of constitutional right and make it more available. which bid for the same number of shares at P44. 3 February 1997] Facts: The Government S ervice Insurance System (GSIS). Hence. so that they can be determined by an examination and construction of its terms. such as those found in Ar ticle II of the 1987 Constitution. Manila Prince Hotel came to the Court on prohibition and man damus.Manila Prince Hotel v. is self-executing. prescribe a practice to be used for its enforcement. but any legislation must be in harmony with the constitution. As against constitutions of the pas t. which off ered to buy 51% of the MHC or 15. In a close bidding held on 18 September 1995 only two bidders participated: Manila Prince Hotel Corporation. or P2. Issue(s): Whether the provisions of the Constitution.00 per share tendered by Renong Berhad in a lette r to GSIS dated 28 September 1995. Pending the declaration of Renong Berhard as the winning bidder/strate gic partner and the execution of the necessary contracts. decided to sell through public bidding 30% to 51% of the issued and outstanding shares of the Ma nila Hotel (MHC). are selfexecuting. and there is no language indicating that the subject is referred to the legislature for action. Thus a constitutional provision is self-executing if the nature and extent of the rig ht conferred and the liability imposed are fixed by the constitution itself. modern constitutions have been generally drafted upon a different principle a nd have often become in effect extensive codes of laws intended to operate direc tly upon the people in a manner similar to that of statutory enactments. is usually not self-executing. The rule is that a selfexecuting provision of the constitution does not necessarily exhaust legislative power on the subject. the Manila Prince Hote l matched the bid price of P44. Subsequent l egislation however does not necessarily mean that the subject constitutional pro vision is not. In self-executing constitutional provisions. Held: A provision which lays down a general principle. particularly Article XII Section 10. The omission from a constitution of any express provision f or a remedy for enforcing a right or liability is not necessarily an indication that it was not intended to be self-executing. fully enforceable.42 more than the bid of pe titioner. by itself. and Renong Berhad. with ITT-Sheraton as its hotel operator. Whether the 51% share is part of the national patrimony. but which GSIS refused to accept.58 per share. On 17 October 1995. a Filipino corporation.00 per share. and the function of constitutional conventions has evolved into one more like that of a legislative body. or place reasonable safeguar ds around the exercise of the right.000 shares at P41. further the operation of such a provision. or that which supplies sufficient rule by means of which the right it grants may be enjoyed or protected. GSIS [GR 122156. Manila Prince Hotel sent a manager s check to t he GSIS in a subsequent letter. unless it is expressly provided that a legislative act is necessary to enforce a . a Malaysian firm.

In the granting of economic rights. If the constitutional provisions are treated as requi ring legislation instead of self-executing. but also to the cultural heritage of the Filipinos. Manil a Hotel has become a landmark. especially on matters involving national patrimony. In its plain an d ordinary meaning. From its very words the pr ovision does not require any legislation to put it in operation. a living testimonial of Philippine heritage. the presumption now is that all provisions of the consti tution are self-executing. the term patrimony pertains to heritage. and to accept the matching bid of Manila Prince H otel at P44 per share and thereafter execute the necessary agreements and docume nt to effect the sale. When the Constituti on speaks of national patrimony. sciences and letters. it refers not only to the natural resources of the Philippines. Section 10. second paragraph. to issue the necessary clearances and to do such other ac ts and deeds as may be necessary for the purpose. The Supreme Court directed the GSIS. XII of the 1987 Constitution is a mandatory. positive command which is complete in itself and which needs no further guidelin es or implementing laws or rules for its enforcement. the Committee on Privatization and the Office of t he Government Corporate Counsel to cease and desist from selling 51% of the Shar e of the MHC to Renong Berhad. pri vileges. as the Constitution could have very well used the term natural resources. a concour se for the elite. the Manila Hotel Corporation. In fine. he latter shall be chosen over the former. t . the legislature would have the power to ignore and practically nullify the mandate of the fundamental law. Art. In the present case.constitutional mandate. Whil e it was restrictively an American hotel when it first opened in 1912. wh en a choice has to be made between a qualified foreigner and a qualified Filipino. and concessions. It also refers to Filipino s intelligence in arts. it has since then become the venue of various significant even ts which have shaped Philippine history.

The functions and public services re ndered by the State cannot be allowed to be paralyzed or disrupted by the divers ion of public funds from their legitimate and specific objects. Disbursements of public funds must be covered by the corr esponding appropriation as required by law.Republic of the Philippines vs. it may limi t claimant's action 'only up to the completion of proceedings anterior to the st age of execution' and that the power of the Courts ends when the judgment is ren dered. . is based on obvious considerat ions of public policy. as appropriated by law. is valid. The universal rule that where the State gives its con sent to be sued by private parties either by general or special law. Villasor [ 54 SCRA 83] Facts: A writ of executio n was issued by the court against the funds of the Armed Forces of the Philippin es to satisfy a judgment rendered against the Philippine Government. Held: It was ruled that public funds cannot be the object of garnishment proceedings eve n if the consent to be sued had been previously granted and even if the State li ability had been adjudged. Issue: Whet her or not the writ of execution. issued by respondent judge. since government funds and properties may not be seized under writs of ex ecution or garnishment to satisfy such judgments.

under the admini stration of te National Resettlement and Rehabilitation Administration (NARRA). introduced various improvements therein an d caused it to be surveyed in July 1952. the Pro clamation is not the legislative act. starte d sub-dividing and distributing the land to the settlers. Feliciano [ 148 SCRA 424 ] Facts: Petitioner seeks the review of the decision of the Intermediate Appellate Court revising the order of the Court of First Instance which dismissed the complaint of Pablo Feliciano for the recover y of ownership and possession of a parcel of land on the ground of non-suability of the State. situated in Barrio of Salvac ion. ISSUE: Can the S tate be sued for recovery and possession of a parcel of land? RULING: No. but must be construed strictly.Republic v.364. either expressly of by implic ation through the use of statutory language too plain to be misinterpreted. Waiver of immunity. the su it against the State. It m ay be invoked by the courts at any stage of the proceedings. the Land Authority. while located within the reservation established under Proclamation No. under settled jurisprudence is not permitted. a tract of land situated in the Municipalities of Tinambac and Siruma. represented by the Land Authority. h e took actual possession of the same. Camarines Sur. The consent of the State to be sued must e manate from statutory authority. Waiver of State immunity can only be made by ac t of the legislative body . that the property in q uestion. Camarines Sur. President Ramon Magsaysay issued a Proclamation No. 1954. Feliciano filed a complain with the Court of First Instance again st the Republic of the Philippines. after which the NARRA and its successor agenby. which survey was approved by the Direct or of Lands on October 24. for the r ecovery of ownership and possession of a parcel of land consisting of four (4) l ots with an aggregated area of 1. 90 reserving for settlement purposes. will not be inferred lightly.4177 hectares. Municipality of Tinambac. 1954. Feliciano alleged that he bought t he property in question for Victor Gardiola by virtue of Contract of Sale and fo llowed by a Deed of Absolute Sale. except upon a showing that the State has consented to be sued. Moreover. was the private property of Feliciano and should therefore be excluded. 90. that his title of ownership based on the informacion posesoria of his predecessor-in-interest be declared legal valid and subsisting and that defenda nt be ordered to cancel and nullify all awards to the settlers. Fel iciano prayed that he be declared the rightful and true owner of the property in question. that Gardiola had acquired the property by pu rchase from the heirs of Francisco Abrazado whose title to the said property was evidenced by an informacion posesoria that upon his purchase of the property. On November 1.

was filed against Bautista in the Regional Trial Court of Tarlac. In G. 80258. On the basis of the sworn statements made by t hem.R. Issue: Whether or not the doctrine of state immunity is applicable on the said cases. officers of the U. In G. He then filed a com plaint for damages against the individual petitioners herein claiming that it wa s because of their acts that he was removed.S. 79470. This was affected on March 5. by Co l. The defendants deny this and clai m the plaintiffs were arrested for theft and were bitten by the dogs because the y were struggling and resisting arrest. It had been ascertained aft er investigation. In G. suspended him and thereafter refe rred the case to a board of arbitrators conformably to the collective bargaining agreement between the Center and its employees. No. Commander of the 3rd Combat Support Group. for injuries allegedly sustained by the plain tiffs as a result of the acts of the defendants. a complaint for damages was filed by the private respondents against the herein petitioners (exc ept the United States of America). otherwise known as the Dangerous Dr ugs Act. King. It is now contesting the denial of its motions by the respondent judges. information for violation of R. Air Force Recreatio n Center at the John Hay Air Station in Baguio City. Genove's reaction was to file a complaint in the Regional Trial Cour t of Baguio City against the individual petitioners. Air Force and special agents of the Air Force Office of Special Investigators (AFOSI). The United States of America was not implea ded in the complaints below but has moved to dismiss on the ground that they are in effect suits against it to which it has not consented.A vs Guinto Facts: Several cases have been consolidated because they all inv olve the doctrine of state immunity. which Genov e had poured urine into the soup stock used in cooking the vegetables served to the club customers. from the testimony of Belsa Cartalla and Orascion. Tomi J.9 There is a conflict of factual allegations here. Bautista was dismissed from his employment.R. No.S. Wilfredo Belsa. Rose Carta lla and Peter Orascion for his dismissal as cook in the U. was arrested following a buy-bust operation conducted by the indiv idual petitioners herein. The defendants stress that the dogs were called off and the plaintiffs were immediately taken to the medical center for treatment of their wounds. In G. No. Dye and Stephen F. Bos tick. PACAF Clark Air Force Base. As a result of the filin g of the charge. Lamachia.A. Luis Bau tista. an extension of Cl ark Air Base. namely. The a bove-named officers testified against him at his trial.S. Air Force stationed in Cla rk Air Base in connection with the bidding conducted by them for contracts for b arber services in the said base. han dcuffed them and unleashed dogs on them which bit them in several parts of their bodies and caused extensive injuries to them.U. the defendants beat them up. 80018. who was employed as a barracks boy in Camp O' Donnell.R.S. 6425. 76607. . According to the plaintiffs. Fabian Genove filed a compla int for damages against petitioners Anthony Lamachia. as club manager. Kimball. David C. the priva te respondents are suing several officers of the U. No. Darrel D. The board unanimously found him guilty and recommended his dismissal. 1986.R.

like any other state. express or implied. this is a matter of evidence. 3083. . at least in democratic societies. A contrary disposition would.Ruling: The answer depends on each and every case involved. the suit must be regarded as against the state itself although it has not been formally impleaded. for the state is not an unfeeling ty rant unmoved by the valid claims of its citizens. On th e contrary. However. it is deemed to have descended to the level of the other contractin g party and divested of its sovereign immunity from suit with its implied consen t. As applied to the lo cal state. The other petitioners in the cases before us all aver they have acted in the discharge of their official functions as officers or age nts of the United States. All states are sovereign equals and cannot assert jurisdiction over one another. non habet imperium. which could serve as a basis of civil action between private parties. The doctrine is sometimes derisively called "the royal pre rogative of dishonesty" because of the privilege it grants the state to defeat a ny legitimate claim against it by simply invoking its non-suability. There is no question that the United States of America. When the government enters into a contract. which has not given its consent to be sued. That is har dly fair. the rule says that the state may not be sued without its consent. the doctrine of state immunity is based on the justification given by Justice Holmes that "there can be no legal right against the authority which ma kes the law on which the right depends." While the doctrine appears to prohibit only suits against the state without its consent. It is only when the contract involves its sovereign or governmental capacity that no s uch waiver may be implied. In fact. the state may move to dismiss the complaint on the ground that it has been filed without its consent. In the case of the foreign state sought to be impleaded in the local jurisdiction. wh ich clearly imports that it may be sued if it consents. the doctrine is not a bsolute and does not say the state may not be sued under any circumstance."12 There are other practical reasons for the enforcement of the doctrine. The charges aga inst them may not be summarily dismissed on their mere assertion that their acts are imputable to the United States of America. the defendants are sought to be held answerable for persona l torts in which the United States itself is not involved. thus opening it self to a counterclaim. The general law waiving the immunity of the state from suit is found in Act No. in the lang uage of a celebrated case. In such a situation. The rule is that if the j udgment against such officials will require the state itself to perform an affir mative act to satisfy the same. If found liable they alone must satisfy the judgment. "unduly vex the peace of nations. it is als o applicable to complaints filed against officials of the state for acts alleged ly performed by them in the discharge of their duties. will be deemed to have impliedly waived its non-suability if it has entered into a contract in its proprietary or private capacity. In fact. the added inhibition is expressed in the ma xim par in parem. under which the Ph ilippine government "consents and submits to be sued upon any moneyed claim invo lving liability arising from contract. such as the appropriation of the amount needed t o pay the damages awarded against them. Waiver is also implied when the government files a complaint.

USA vs. Issue: Whether the US naval base in bidding for said contracts exercise governme ntal functions to be able to invoke state immunity. Fo r this reason. The ba se was one of those provided in the military bases agreement between Phil and th e US Respondent alleges that it won in the bidding conducted by the US for the c onstruction of wharves in said base that was merely awarded to another group. its c ommercial activities of economic affairs. a function of the government of highest order. commercial and proprietary act s. In this case. It has been necessary to distinguish them bet ween sovereign and governmental acts and private. Only when it enters into business contracts. they are continually and evolving and because the act ivities of States have multiplied. A State may be descended to the level of an individual and can thus be deemed to have tacitly given its consent to be sued. This rule is necessary consequence of the pr inciple of independence and equality of States. nor dedicated to commercial or business purposes. it does not apply where the c ontracts relates the exercise of its sovereign function. a suit for specific performance was filed by him against the US. they a re not utilized for . The result is that State immunity now extends only to sovereign and governmen tal acts. The restrictive application of state immunity is proper only when the proceedings arise out of commercial transactions of the foreign sovereign. indisputably.. the rules of internatio nal law are not petrified. However. Ruiz [136 SCRA 487] Facts: The USA had a base in Subic. . Zambales. Held: The traditional role o f the state immunity excerpts a state from being sued in the courts of another S tate without its consent or waiver. the proje ct are integral part of the naval base which is devoted to the defense of both U S and Phil.

the claim for moral da mages. who disallowed it in his 9th Endorsement. the complaint was dismissed. 1959. she could bring an action to recover possession of t he portion of land in question at anytime because possession is one of the attri butes of ownership. being a money claim against the government. plaintiff had no cause of action against the defendants. No. the basis should be the price or v alue thereof at the time of the taking. Thus. the amount of w hich should be fixed by the trial court after hearing. the decision a ppealed from is hereby set aside and the case remanded to the court a quo for th e determination of compensation. As regards the claim for damages. the government used a portion of said lot for the construction of the Mango and Gorordo Avenues. CUENCA [G. Conside ring that no annotation in favor of the government appears at the back of her ce rtificate of title and that she has not executed any deed of conveyance of any p ortion of her lot to the government. In addition. the pl aintiff is entitled thereto in the form of legal interest on the price of the la nd from the time it was taken up to the time that payment is made by the governm ent. the court rendered its decision holding that it had no jurisdiction over the pl aintiff's cause of action for the recovery of possession and ownership of the lo t on the ground that the government cannot be sued without its consent.AMIGABLE vs. (3) that the action being a suit against the Government. requesting payment of the portion of her lot which had been app ropriated by the government. The claim was indorsed to the Auditor General. is the registered owner of a lot in Cebu City. On July 29. Accordingly. As registered owner. the claim not having been filed first with the Office of the Audito r General. against the Republic of the Philippines and Nicolas Cuenca (Commissio ner of Public Highways) for the recovery of ownership and possession of her lot.R. To determine the due compensation for the land. nor did it have jurisdiction over said claim because the government had not given its consent to be sued. 1972] FACTS: Victoria Amigabl e. However. since restoration of possession of said portion by the government is neither convenient nor feasible at this time because it is now and has been used for road purposes. Amigable filed in the court a quo a complaint. The defendants denied the plaintiff s allegations stating: (1) that the action wa s premature. the appellant remains the owner of the whol e lot. that it had neither original nor appellate jurisdiction to hear and decide plaintiff's c laim for compensatory damages. WHEREFORE. Amigable's counsel wrote to the President of the Philippines. L-26400 February 29. attorney's fees and costs had no valid basis since the Government had not given its consent to be sued. Without prior expropriation or negotiated sale. (2) that the right of action for the recovery had already prescribed. ISSUE: Can the appellant sue the government RULING: Yes. the government should pay for attorney's fees. . the only relief available is for the gover nment to make due compensation which it could and should have done years ago. and (4) that inasmuch as it was the province of C ebu that appropriated and used the area involved in the construction of Mango Av enue. and t hat it had long prescribed. including attorney's fees. to which the appella nt is entitled as above indicated.

June 15. it abandons its sovereign capacity and is to be treated like any other corporation. It is to be admitted that under the present Constitution. L-33112. Held: The certiorari was dismissed without cost by the Supreme C ourt saying that the funds held by PNB is subject for garnishment." In addition. what was formerly implicit as a fundamental doctrine i n constitutional law has been set forth in express terms: "The State may not be sued without its consent. the wri t of execution be imposed immediately. The non-suability clause raised by PVTA b eing a government owned corporation was also denied citing previous decisions he ld by the Supreme Court specifically citing that of Manila Hotel Employees Assoc iation vs Manila Hotel Company and to quote 'it is well-settled that when the go vernment enters into commercial business.1978] Issue: The petitioner is reques ting for certiorari against the writ of execution authorized by the Hon Judge Pa balan regarding the transfer of funds amounting to P12. PABALAN [G. Facts: Philippine National Bank invoked t he doctrine of non-suability in behalf of PVTA.R.PNB vs.724. . the amount held by said bank is subject to garnishment.66 belonging to Phill ipine Virginia Tobacco Administration. No. thus.

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